Privacy Policy (Refuge)

Privacy Policy

Last updated: May 6, 2026

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Business, for the purpose of the CCPA (California Consumer Privacy Act, as amended by the CPRA), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to CVAC, Inc., 27300 Rancho San Carlos Road.

Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: California, United States

Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.

Sensitive Personal Information, for the purpose of the CCPA, means personal information that reveals a consumer's social security, driver's license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer's mail, email, and text messages; genetic data; neural data; and the personal information of consumers known to be under 16 years of age.

Share or Sharing, for the purpose of the CCPA, means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to a third party for cross-context behavioral advertising.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Refuge, accessible from www.Refuge.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Usage Data

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, pixels, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
Web Beacons and Pixels: Certain sections of our Service and our emails may contain small electronic files known as web beacons or pixels that permit the Company, for example, to count users who have visited those pages or opened an email, track advertising conversions, and for other related website statistics.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies (Session): Essential to provide You with services available through the Website and to enable You to use some of its features.
Cookies Policy / Notice Acceptance Cookies (Persistent): Identify if users have accepted the use of cookies on the Website.
Functionality Cookies (Persistent): Allow us to remember choices You make when You use the Website, such as remembering your login details or language preference.
Tracking and Performance Cookies (Persistent): Used to track information about traffic to the Website, how users use the Website, and to facilitate targeted advertising.

Consent Symmetry and Dark Patterns: Please note that closing, dismissing, or navigating away from our cookie consent banner without affirmatively selecting "Accept" does not constitute consent. We will automatically treat an ignored or dismissed banner as a denial of consent for non-essential tracking and advertising cookies.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: To manage Your registration as a user of the Service.
For the performance of a contract: The development, compliance, and undertaking of the purchase contract for products or services.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication.
To provide You with news and offers: Special offers and general information about other goods, services, and events.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
For other purposes: Such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and improving our Service.

We may share Your personal information in the following situations:

With Service Providers: To monitor and analyze the use of our Service, advertise to You, or contact You.
For business transfers: In connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition.
With Affiliates: We may share Your information with Our affiliates, requiring them to honor this Privacy Policy.
With business partners: To offer You certain products, services, or promotions.
With other users: When You share personal information or otherwise interact in the public areas with other users.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention, Transfer, and Disclosure of Your Personal Data

Retention of Your Personal Data

We retain your personal information based on the following criteria:

Category A & B (Identifiers & Customer Records): Retained for the lifetime of your active Account, plus up to 7 years to comply with legal, tax, or accounting obligations.
Category F (Internet/Network Activity): Analytics and tracking data (including Meta Pixel and Google Analytics) are generally retained for 14 to 26 months before being aggregated or deleted.
Marketing Data: Retained until you opt-out or withdraw consent.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

Disclosure of Your Personal Data

We may disclose Your Personal Data in the following situations:

Business Transactions: If the Company is involved in a merger, acquisition, or asset sale.
Law enforcement: If required to do so by law or in response to valid requests by public authorities.
Other legal requirements: To comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing, protect the personal safety of Users, or protect against legal liability.

Security of Your Personal Data

While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security over the Internet.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics and Advertising

We use third-party Service providers to monitor and analyze the use of our Service, as well as to advertise to You on third-party platforms.

Google Analytics: A web analytics service offered by Google that tracks and reports website traffic. This data is shared with other Google services and may be used to contextualize and personalize the ads of its own advertising network. You can opt-out by installing the Google Analytics opt-out browser add-on. For more information, visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Google AdWords (Google Ads): We use Google Ads remarketing and conversion tracking services to advertise on third-party websites (including Google) to previous visitors to our site. Google uses cookies to serve ads based on someone's past visits to our Service. You can set preferences for how Google advertises to you using the Google Ad Preferences page.
Meta Pixel: We utilize the Meta (Facebook) Pixel to understand how You interact with our Website and to serve targeted advertisements to You on Meta platforms (Facebook, Instagram). The Meta Pixel collects data that helps us track conversions from Meta ads, optimize ads, build targeted audiences for future ads, and remarket to people who have taken action on our website. You can control how Meta uses data to show you ads by adjusting your ad preferences within your Facebook or Instagram account settings.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link in any email.

Zenoti: We use Zenoti as an email marketing service provider. Their Privacy Policy can be viewed at https://www.zenoti.com/trust/privacy-notice

CCPA Privacy (California Consumer Privacy Rights Act)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. Below are the categories of personal information we may have collected within the last twelve (12) months:

Category A: Identifiers. (Examples: Name, address, email, IP address). Collected: Yes.
Category B: Personal info in CA Customer Records statute. (Examples: Name, phone number, financial information). Collected: Yes.
Category C: Protected classification characteristics. Collected: No.
Category D: Commercial information. Collected: No.
Category E: Biometric information. Collected: No.
Category F: Internet or similar network activity. (Examples: Interaction with our Service, Pixel tracking, Google Ads, email tracking). Collected: Yes.
Category G: Geolocation data. Collected: No.
Category H: Sensory data. Collected: No.
Category I: Professional or employment-related information. Collected: No.
Category J: Non-public education information. Collected: No.
Category K: Inferences drawn from other personal information. Collected: No.
Category L: Sensitive Personal Information. Collected: Yes (e.g. Account log-in combined with a password).

Sources of Personal Information

We obtain the categories of personal information listed above directly from You (forms You complete), indirectly from You (observing activity on our Service), automatically from You (through cookies/pixels We or our Service Providers set), and from Service Providers (third-party analytics and advertising vendors).

Use of Personal Information for Business or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" to operate our Service, provide support, fulfill inquiries, respond to law enforcement, detect security incidents, and market our services (including cross-context behavioral advertising).

Disclosure, Sale, and Sharing of Personal Information

As defined in the CCPA (as amended by CPRA), "sell" means disclosing personal information for valuable consideration, and "share" means disclosing personal information for cross-context behavioral advertising (such as via Google AdWords or Meta Pixel).

We may sell, share, or disclose for a business purpose the following categories of personal information:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute
Category F: Internet or other similar network activity
Category L: Sensitive Personal Information (Disclosed to Service Providers for business purposes only)

We share this information with Service Providers, affiliates, business partners, and advertising networks.

Protection of Minors: We do not knowingly sell or share the personal information of Consumers under 16 years of age. Under California law, the personal information of consumers under 16 is legally classified as Sensitive Personal Information. If We gain actual knowledge that a consumer is under 16, We will default to opting them out of all data Sales and Sharing.

Your Rights under the CCPA/CPRA

If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which it is being used.
The right to request/know. You have the right to request that We disclose information to You about Our collection, use, sale, and sharing of personal information. You may request access to the specific pieces of personal information we have collected about you going back to January 1, 2022, unless doing so proves impossible or would involve a disproportionate effort.
The right to correct. You have the right to request the correction of inaccurate personal information that we maintain about you.
The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell or share Your personal information for cross-context behavioral advertising.
The right to limit the use of Sensitive Personal Information. You have the right to direct us to limit our use of sensitive personal information. (Note: We only use sensitive personal information as necessary to perform the services reasonably expected by an average consumer, such as providing account access).
The right to opt-out of Automated Decision-Making and Profiling. We do not use your personal information for Automated Decision-Making Technology (ADMT) or profiling that produces legal or similarly significant effects concerning you. Therefore, this right is satisfied by our current operational practices.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data from our records, subject to certain legal and operational exceptions.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer rights under California law.

Exercising Your CCPA/CPRA Rights

To exercise any of Your rights, You can contact Us:

By email: Concierge@Refuge.com
By phone number: 831.620.7360

Only You, or an authorized agent, may make a verifiable request related to Your personal information. We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request.

Do Not Sell or Share My Personal Information

You have the right to opt-out of the sale and sharing of Your personal information. Our use of Meta Pixel, Google Analytics, and Google AdWords may constitute a "sale" or "share" under California law.

Opt-Out Preference Signals & Confirmation

We recognize and process recognized Opt-Out Preference Signals, such as the Global Privacy Control (GPC), in a frictionless manner. If you broadcast the GPC signal through your browser, we will automatically treat this as a valid request to opt-out of the Sale and Sharing of your personal information. Upon successfully processing your GPC signal or manual opt-out request, our Website will provide a visual confirmation (e.g., displaying "Opt-Out Request Honored" or reflecting the choice in a privacy toggle) to verify your opt-out status.

You can also opt-out of cross-context behavioral advertising and tracking manually:

Use the NAI's opt-out platform: https://optout.networkadvertising.org/
Use the EDAA's opt-out platform http://www.youronlinechoices.com/
Use the DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
Opt out of interest-based ads via your mobile device settings (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android).

"Do Not Track" Policy (CalOPPA)

Our Service does not respond to older Do Not Track signals, but as noted above, we do honor recognized Opt-Out Preference Signals like the Global Privacy Control (GPC). You can set Your preferences in Your web browser to inform websites that You do not want to be tracked.

Your California Privacy Rights (Shine the Light law)

Under California Civil Code Section 1798, California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. Contact Us using the information below to request this.

California Privacy Rights for Minor Users

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites to request and obtain removal of content or information they have publicly posted. Contact Us to request removal.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.